SEC v. Retirement Surety LLC Crescendo Financial LLC Rose and others (unregistered distributions, 2019)

On appeal

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In December 2019 an SEC administrative law judge ordered Thomas Rose, David Leeman and David Featherstone to disgorge commissions from unregistered securities sales, totalling $382,084, plus $3,750 penalties each.

The record

What was ordered

Civil penalty

$11.3k

Disgorgement

$382k

Prejudgment interest

—

Total relief

$393k

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

On December 20, 2019 an SEC administrative law judge issued an initial decision following a 2017 settlement order in which Retirement Surety LLC, Crescendo Financial LLC, Rose, Leeman and Featherstone were found to have violated Securities Act Sections 5(a) and 5(c) and Exchange Act Section 15(a)(1) by selling unregistered Verto Capital Management notes as unregistered brokers. The decision orders disgorgement of $297,360 from Rose, $24,343.50 from Leeman and $60,380 from Featherstone, with interest, and a $3,750 first-tier penalty on each. The $7,000 the record previously showed was a New Jersey commission repayment by a different person, Schantz, mentioned as background. The record also garbled the names.

This library tags the matter as unregistered distributions, based on the conduct the document describes. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Unregistered distributions — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2019-12-20 Initial decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• Initial decision (ID-1392)
• Order instituting proceedings
• Finality order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.